Steven M. Przesmicki
+1 858 550 6070
przes@cooley.com
February 19, 2021
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attn: Margaret Schwartz
Jeffrey Gabor
Jeanne Bennett
Mary Mast
Re: Longboard Pharmaceuticals, Inc.
Amendment No. 1 to Draft Registration Statement on Form S-1
Submitted January 29, 2021
CIK No. 0001832168
Ladies and Gentlemen:
On behalf of Longboard Pharmaceuticals, Inc. (the “Company”), we are responding to the comment (the “Comment”) of the staff (the “Staff”) of the Securities and Exchange Commission contained in its letter, dated February 11, 2021, relating to the above referenced confidential Amendment No. 1 to Draft Registration Statement on Form S-1. In response to the Comment, the Company has revised its disclosure on page 99 of its Registration Statement on Form S-1 (the “Registration Statement”), which has been publicly filed via EDGAR on the date of this response letter. The Company respectfully advises the Staff that the studies shown in the comparison on page 99 of the Registration Statement are in vitro preclinical studies, and has disclosed additional details regarding the studies describing the protocol and how the results were measured.
The Company respectfully requests the Staff’s assistance in completing the review of the Registration Statement as soon as possible. Please advise us if we can provide any further information or assistance to facilitate your review. Please contact me at (858) 550-6070, Charles S. Kim of Cooley LLP at (858) 550-6049, or Asa M. Henin of Cooley LLP at (858) 550-6104 with any questions or further comments regarding our response to the Comment.
Sincerely,
| /s/ Steven M. Przesmicki |
| Steven M. Przesmicki |
| Cooley LLP |
cc: Kevin R. Lind, Longboard Pharmaceuticals, Inc.
Brandi L. Roberts, Longboard Pharmaceuticals, Inc.
Charles S. Kim, Cooley LLP
Asa M. Henin, Cooley LLP
Cheston J. Larson, Latham & Watkins LLP
Matthew T. Bush, Latham & Watkins LLP
Chris C. Geissinger, Latham & Watkins LLP
Cooley LLP 4401 Eastgate Mall San Diego, CA 92121-1909
t: (858) 550-6000 f: (858) 550-6420 cooley.com